USA v. RoofMOTIOND.S.C.January 9, 2017IN THE DISTRICT COURT OF THE UNITED STATES FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION FILED UNDER SEAL UNITED STATES OF AMERICA ) ) v. ) CASE NO.: 2: 1 S-CR-472 ) DYLANN STORM ROOF ) This motion is in anticipation of closing argument, to prevent unfair and unconstitutional comments by the government that may unfairly prejudice the jury. I have attached as Exhibit 1 to this motion a motion in limine containing twenty-seven objections to common improper arguments, which could be made here. In addition, I object to any of the following comments (or comments like them). 1. References to "evil". See Exhibit 1 at item 17, p. 64; item 24, p. 94. 2. Reference to the "pit of hell". See id. 3. Uses ofthe word "hate", and variations of the word (e.g., "hateful", "heart of hate", etc.), other than in discussing the hate crime counts as predicates for the 924(j) counts. See Exhibit 1, item 24, p. 94. 4. References to particularly inflammatory terms relating to the views expressed in my writings. Cf Dkt. No. 738 at 12-13; see also Exhibit 1, item 24, p. 94 & n.36 (reference to Hitler).' , Other examples might include "Holocaust" or "lynching." 2:15-cr-00472-RMG Date Filed 01/09/17 Entry Number 865 Page 1 of 3 5. References to the "particularly good" victims (a statement made by Mr. Richardson on January 5,2017), and similar references, especially references that imply or directly suggest a comparison to the defendant. See Exhibit] at item 7, p. 27. 6. References to what "God" told the victims or witnesses, or what witnesses feel the victims "wanted" the jury to see, see Exhibit 1 at item 17, p. 64; item 19, p. 20. 7. References to my demeanor during the trial, see Exhibit 1 at item 22, p. 88; see also Court's Demeanor Instruction. 8. References to Reverend Simmons's firearm, and in particular, any argument or implication that jurors should do what he could not, by imposing the death penalty. See Exhibit I, at item 4, p. 17; item 5, p. 20; item 11, p. 41. 9. Any argument suggesting that the jury should reject a life sentence because it is the "minimum" sentence available. 10. References to providing "closure", since the research is inconsistent on whether a life sentence or a death sentence provides better closure for victims' families. See, e.g., Marilyn Peterson Armour, Ph.D. & Mark S. Umbreit, Ph.D., "The Ultimate Penal Sanction and 'Closure' for Survivors of Homicide Victims, 91 Marq. L. Rev. 381 rcsources#Studiesresources#Studics. During closing argument, I request that the Court permit me - when the government makes an improper argument, simply to object and say that I refer to my motion. I also request that the Court instruct the government to be familiar with the legal principles in the Exhibit. Respectfully submitted, Dvi0nn RoaL 7 2:15-cr-00472-RMG Date Filed 01/09/17 Entry Number 865 Page 2 of 3 ,; I Dylann S. Roof January R, 2017 2:15-cr-00472-RMG Date Filed 01/09/17 Entry Number 865 Page 3 of 3
